DAQ-2024-011872

DAQE-AN104230018-24

{{$d1 }}

Joseph Eck
Interstate Brick Company
9780 South 5200 West
West Jordan, UT 84081-5625
[e-mail]

Dear Mr. Eck:

Re: Approval Order: Modification to Approval Order DAQE-AN104230017-16 to Account for
Existing Operations
Project Number: N104230018

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on February
10, 2023. Interstate Brick Company must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is John Jenks, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received on
this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:JJ:jg

cc: Salt Lake County Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

December 3, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN104230018-24
Modification to Approval Order DAQE-AN104230017-16 to
Account for Existing Operations

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Interstate Brick Company - Brick Manufacturing Plant

Issued On
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Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

December 3, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 16
ACRONYMS ............................................................................................................................... 17

DAQE-AN104230018-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Interstate Brick Company Interstate Brick Company - Brick Manufacturing Plant

Mailing Address Physical Address
9780 South 5200 West 9780 South 5200 West
West Jordan, UT 84081-5625 West Jordan, UT 84081-5625

Source Contact UTM Coordinates
Name: Greg Stevenson 413,500 m Easting
Phone: [phone],491,500 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12
SIC code 3251 (Brick & Structural Clay Tile)

SOURCE INFORMATION
General Description
Interstate Brick Company (ISB) operates a brick and tile manufacturing plant in West Jordan City, Salt
Lake County, Utah. The operation includes raw material (clays) storage, crushing/blending operations,
and three natural gas-fired kilns used to fire the products. Crushing and screen operations are controlled
with baghouses.

NSR Classification
Minor Modification at Major Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA
Salt Lake County
Airs Source Size: A

Applicable Federal Standards
Title V (Part 70) Major Source

DAQE-AN104230018-24
Page 4

Project Description
This modification includes:

1. The addition of emissions from crushing and screening as a result of baghouse vent reconfiguration.
Previously, on-site baghouses vented internally, causing hazardous indoor conditions. As a remediation to
internal dust issues, the baghouses will now vent out of the building. This change will result in an
increase in PM10 and PM2.5 emissions.

2. A reduction in NOx emissions. Reductions are based on 20+ years of emission testing on Kiln #3 and
Kiln #4. The new kiln lb/hr limits will be added (4.70 lb/hr for Kiln #3 and 6.40 lb/hr for Kiln #4). This
reduction will remove IBS from SIP consideration; testing for these kilns will be increased from every
five years to every year.

3. Site-wide conditions were updated to comply with administrative standards and updates. There were no
changes to requirements as a result of these updates beyond the reduced NOx rates and increased
NOx-based stack testing frequency. Speed-related requirements were removed as emissions for hauling
are limited by the 20% opacity requirements for fugitive emissions.

4. ISB submitted a second notification for the inclusion of a replacement soda ash silo and controlling bin
vent. This project will be consolidated into the permit modification. The replacement silo and bin vent
will not increase total soda ash usage or expected emissions. The silos were labeled as "lime silos"
(II.A.7) in the existing AO. This label will be updated.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
Carbon Monoxide 0 219.48
Nitrogen Oxides -19.68 49.35
Particulate Matter - PM10 2.05 63.34
Particulate Matter - PM10 (Fugitives) 0 45.68
Particulate Matter - PM2.5 2.05 63.34
Sulfur Dioxide 0 69.00
Volatile Organic Compounds 8.01 14.87

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 14400
Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 0 13400
Organic HAPs (CAS #OHAPS) 0 8600
Change (TPY) Total (TPY)
Total HAPs 0 18.20

DAQE-AN104230018-24
Page 5

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. [R307-150]
I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Brick and Tile Manufacturing Plant
II.A.2 Line #1

A. Tunnel Kiln #1 (not operational)
II.A.3 Line #3 A. Line #3 kiln with packed tower scrubber and mist eliminator Scrubber air flow - 60,000 Actual Cubic Feet per Minute (ACFM) B. Line 3 baghouse - MikroPul
DAQE-AN104230018-24
Page 6

II.A.4 Line #4 A. Line #4 kiln Wet scrubber and mist eliminator Scrubber air flow - 89,800 ACFM B. Line #4 vacuum cleaner C. Line #4 shapes dryer D. Line #4 baghouse - MikroPul II.A.5 Grizzly Hopper
II.A.6 Primary and Secondary Crushers A. Primary crusher with baghouse Crusher manufacturer - Stedman Capacity: 100 tons per hour Control: Pulse jet baghouse Installed before August 31, 1983 B. Secondary crusher/grinding Installed before August 31, 1983 C. Screens Installed before August 31, 1983
II.A.7 Silos
Two soda ash silos Controlled by bin vent

II.A.8 Clay Storage Piles II.A.9 Miscellaneous Diesel Equipment

II.A.10 Miscellaneous Equipment Extruder Vacuum Pumps, Storage Tanks, Vehicle Fueling Tanks, Space Heaters. This equipment is listed for informational purposes only.

DAQE-AN104230018-24
Page 7

SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Limitations and Test Procedures
II.B.1.a The following limitations shall not be exceeded:

A. Plant wide production/consumption limits

1) 2,880 tons raw clay consumption per rolling 24-hour period.

2) 393,236 tons of brick produced in Line #3 and Line #4 combined per
rolling 12-month period.

3) 512,582 tons of brick produced plantwide per rolling 12-month period.

B. Tunnel Kiln #1 (Not operational until scrubber is online)
13.62 tons of product per hour averaged over a rolling 24-hour period.

C. Tunnel Kiln #3
17.92 tons of product per hour averaged over a rolling 24-hour period.

D. Tunnel Kiln #4
26.97 tons of product per hour averaged over a rolling 24-hour period.

E. Clay Prep for Line 3 not Including Kiln # 3
6,240 hours of operation per rolling 12-month period.

F. Clay Prep for Line 4 not Including Kiln # 4
6,240 hours of operation per rolling 12-month period.

To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months.
Records of consumption, production and or hours of operation shall be kept for all periods when
the plant is in operation. Production/consumption shall be determined by operator logs. The
records of consumption/production shall be kept on a daily basis. Hours of operation shall be
determined by monitoring and maintaining an operations log.

[R307-401-8]

DAQE-AN104230018-24
Page 8

II.B.1.b Visible emissions from the following emission points shall not exceed the following values: A. All screens - 10% opacity. B. All conveyor transfer points - 10% opacity. C. All baghouses - 10% opacity. D. All buildings enclosing crushers - 10% opacity. E. All crushers - 15%. F. All other points - 20% opacity. Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.c The owner/operator shall apply water to storage piles to maintain the opacity limits as required in
this AO. [R307-401-8]
II.B.1.d The owner/operator shall not operate Kiln #1 until the replacement scrubber for Kiln #1 has been approved in accordance with R307-401-8. [R307-401-8] II.B.1.e The owner/operator shall route all emissions from the primary crusher building through the
primary crusher baghouse prior to venting to the atmosphere. [R307-401-8]

II.B.1.f The owner/operator shall vent all process streams and exhaust air from Kiln #3 to a wet scrubber shall control process streams from Kiln #3 prior to venting to the atmosphere. [R307-401-8]
II.B.1.g The owner/operator shall vent all process streams and exhaust air from Kiln #4 through the wet scrubber prior to venting to the atmosphere. [R307-401-8]

DAQE-AN104230018-24
Page 9

II.B.1.h The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s): Scrubber Tunnel Kiln #3 NOx: 1-hr average 4.70 lb/hr PM10: 1-hr average 8.66 lb/hr PM2.5: 1-hr average 8.66 lb/hr SO2: 1-hr average 8.09 lb/hr Total Fluorides: 1-hr average 1.77 lb/hr Scrubber Tunnel Kiln #4 NOx: 1-hr average 6.40 lb/hr PM10: 1-hr average 3.97 lb/hr PM2.5: 1-hr average 3.97 lb/hr SO2: 1-hr average 5.87 lb/hr Total Fluorides: 1-hr average 3.25 lb/hr Line #3 Baghouse (dry filterable particulate only) PM10: 1-hr average 0.18 lb/hr Maximum Concentration: 0.016 grains/dscf PM2.5: 1-hr average 0.18 lb/hr Maximum Concentration: 0.016 grains/dscf Line #4 Baghouse (dry filterable particulate only) PM10: 1-hr average 0.34 lb/hr Maximum Concentration: 0.016 grains/dscf PM2.5: 1-hr average 0.34 lb/hr Maximum Concentration: 0.016 grains/dscf Primary Crusher Baghouse Vent (dry filterable particulate only) PM10: 1-hr average 0.56 lb/hr Maximum Concentration: 0.010 grains/dscf PM2.5: 1-hr average 0.56 lb/hr Maximum Concentration: 0.010 grains/dscf [R307-401-8]
II.B.1.h.1 To demonstrate compliance with the emission limitations above, the owner/operator shall
conduct emission testing (stack testing) as outlined below. [R307-401-8]
II.B.1.h.2 Test Frequency The owner/operator shall conduct subsequent PM10 and PM2.5 emission tests within five years after the date of the most recent emission test for all units. NOx emissions from Kiln #3 and Kiln #4 shall be tested annually. The Director may require the owner/operator to perform an emission test at any time. [R307-165-2, R307-401-8]
DAQE-AN104230018-24
Page 10

II.B.1.h.3 Notification At least 30 days prior to conducting an emission test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include: A. The date, time, and place of the proposed test. B. The proposed test methodologies. C. The stack to be tested. D. The procedures to be used. E. Any deviation from an EPA-approved test method. F. Explanation of any deviation from an EPA-approved test method. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-2, R307-401-8]
II.B.1.h.4 Testing The owner/operator shall conduct testing according to the approved source test protocol. The
Director may reject emission test data if the test did not follow the approved source test protocol
or if Director was not provided an opportunity to have an observer present at the test. [R307-165-5, R307-401-8]

II.B.1.h.5 Test Conditions The owner/operator shall conduct all tests while the source is operating at the maximum production or combustion rate at which the source will be operated unless otherwise specified in the approved source test protocol. During the tests, the owner/operator shall burn fuels or combinations of fuels, use raw materials, and maintain process conditions representative of normal operations. In addition, the owner/operator shall operate under any other relevant conditions that the Director specifies. [R307-165-4, R307-401-8] II.B.1.h.6 Standard Conditions & Emission Limit Parameters

A. Temperature - 68 degrees Fahrenheit (293 K).
B. Pressure - 29.92 in Hg (101.3 kPa).
C. Concentration (ppmdv) - 3% oxygen, dry basis.

D. Averaging Time - As specified in the applicable test method.
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.1.h.7 Reporting Within 60 days after completing an emission test, the owner/operator shall submit a copy of the test results to the Director. [R307-401-8]
II.B.1.i Test Methods
When performing emission testing, the owner/operator shall use the appropriate EPA-approved
test methods as acceptable to the Director. Acceptable test methods for pollutants are listed
below. [R307-401-8]

DAQE-AN104230018-24
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II.B.1.i.1 PM2.5 Total PM2.5 = Filterable PM2.5 + Condensable PM2.5 Filterable PM2.5 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A, or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM2.5. Condensable PM2.5 40 CFR 51, Appendix M, Method 202, or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.1.i.2 PM10
Total PM10 = Filterable PM10 + Condensable PM10
Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10.
Condensable PM10
40 CFR 51, Appendix M, Method 202, or other EPA-approved testing method as acceptable to
the Director.
Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10 fraction of the filterable particulate emissions,
all of the filterable particulate emissions shall be considered PM10.
[R307-401-8]

II.B.1.i.3 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.1.i.4 SO2
40 CFR 60, Appendix A, Method 6 or 6C, or other EPA-approved method as acceptable to the
Director. [R307-165]
II.B.1.i.5 Total Fluorines 40 CFR 60, Appendix A, Method 13B; 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow rate or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.1.j The moisture content of the clay shall be maintained at an average of no less than 4.0% by
weight. The moisture content shall be tested if directed by the Director using the appropriate
ASTM method. [R307-401-8]

DAQE-AN104230018-24
Page 12

II.B.2 Fuels II.B.2.a The owner/operator shall only use natural gas as a fuel and propane as a backup fuel in the kilns.
[R307-401-8]
II.B.3 Monitoring - General Process II.B.3.a The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the
continuous measurement of the change in pressure of the gas stream through the baghouse and scrubbers.
A. The minimum pressure drop in inches/w.g. for the baghouse and scrubbers shall be as follows:
1) Primary crusher baghouse with polyester felt 2.0 with PTFE membrane 0.4
2) Kiln 3 scrubber 0.1

3) Kiln 4 scrubber 2.0
The monitoring device must be certified by the manufacturer to be accurate within
plus or minus 5% of the w.g. design measuring device and must be calibrated on an annual basis in accordance with the manufacturer's instructions. When the
scrubber(s) are in operation, the pressure drop shall be within the limits specified
above except during start-up and shut-down of the scrubber(s). When the primary crusher baghouse is in operation; the pressure drop shall be within the limits
specified above, except during a period of ten crusher operating days following the
filter media replacement.
B. Monitoring
Once per operating day for each scrubber, ISB shall verify that the differential pressure is within the permitted range. All pressure gauges shall be located such
that an inspector/operator can safely read the indicator at any time.
C. Record Keeping
Results of the change in pressure shall be recorded on a daily basis. Continuous
recording for the monitoring device is not required.
[R307-401-8]

DAQE-AN104230018-24
Page 13

II.B.3.b The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the pH of the scrubbing solution of the gas stream through each scrubber. A. The pH range for the scrubbers shall be as follows: 1) Kiln 3 5-9 2) Kiln 4 5-9 The monitoring device must be certified by the manufacturer to be accurate within plus or minus 5% of the design pH and must be calibrated on an annual basis in accordance with the manufacturer's instructions. When the scrubber(s) are in operation, the pH shall be within the ranges specified above except during start-up and shut-down of the scrubber(s). B. Monitoring Once per operating day for each scrubber, ISB shall verify that the pH is within the permitted range. All meters shall be located such that an inspector/operator can safely read the indicator at any time. C. Record Keeping Results of the pH shall be recorded on a daily basis. Continuous recording for the monitoring device is not required. [R307-401-8] II.B.3.c The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the
continuous measurement of the flow rate of the scrubbing solution of the gas stream through
each scrubber.
A. The minimum scrubbing liquid flow rate in gallons per minute (gpm), for the scrubbers
shall be as follows:
1) Kiln 3 200
2) Kiln 4 600

The monitoring device must be certified by the manufacturer to be accurate within plus or minus 5% of the design scrubbing liquid flow rate and must be calibrated on an
annual basis in accordance with the manufacturer's instructions. When the scrubber(s)
are in operation, the scrubbing liquid flow rate shall be no less than the flow rates specified above, except during start-up and shut-down of the scrubber(s).

B. Monitoring Once per operating day for each scrubber, ISB shall verify that the liquid flow rate
is within the permitted range. All flow gauges shall be located such that an
inspector/operator can safely read the indicator at any time.

C. Record Keeping
Results of the scrubbing liquid flow rate shall be recorded on a daily basis.
Continuous recording for the monitoring device is not required.

[R307-401-8]

DAQE-AN104230018-24
Page 14

II.B.4 VOC and HAP Limitations II.B.4.a The plant-wide emissions of VOCs from the brick manufacturing plant and associated operations
shall not exceed 14.87 tons per rolling 12-month period for VOCs. Compliance with the limitation shall be determined on a rolling 12-month total. Based on the
twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months.
The VOC emissions shall be determined by maintaining a record of VOC-emitting materials used each month. The record shall include the following data for each material used:
A. Name of the VOC-emitting material, such as paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc.
B. Density of each material used (pounds per gallon).
C. Percent by weight of all VOC in each material used.
D. Gallons of each VOC-emitting material used.

E. The amount of VOC emitted monthly by each material used shall be calculated by the following procedure:

VOC = % VOC by Weight x [Density (lb)] x Gal Consumed x 1 ton (100) (gal) 2000 lb

F. The amount of VOC emitted monthly from all materials used.
G. The amount of VOCs reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above to provide the monthly total VOC emissions.

[R307-401-8]
DAQE-AN104230018-24
Page 15

II.B.4.b The plant-wide emissions of HAPs from the brick manufacturing plant and associated operations shall not exceed: 7.2 tons per rolling 12-month period for HCl. 6.7 tons per rolling 12-month period for HF. 7.0 tons per rolling 12-month period for miscellaneous HAPs. 18.2 tons per rolling 12-month period for all HAPs combined. Compliance with the limitation shall be determined on a rolling 12-month total. Based on the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months. Compliance with HF and HCl limitations listed above shall be determined through a method of mass balance. The mass balance plan approved by the Director was submitted by ISB on October 22, 2009. If ISB submits any additional revised mass balance methods for determining annual emissions to the Director for approval, the plan shall include, at a minimum, the following: A. Proposed test methods and test frequency for determining the weight of the elemental fluorine contained in the clays used to manufacture brick. B. Proposed test methods and test frequency for determining the weight of the elemental fluorine contained in the finished product. C. Calculation method of determining emissions of HCL and HF, which will demonstrate compliance with the HCl and HF emission limitations listed above. The miscellaneous HAP emissions shall be determined by maintaining a record of HAP-emitting materials used each month. The record shall include the following data for each material used: D. Name of the HAP-emitting material, such as paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. E. Density of each material used (pounds per gallon). F. Percent by weight of all HAP in each material used. G. Gallons of each HAP-emitting material used. H. The amount of HAP emitted monthly by each material used shall be calculated by the following procedure: HAP = % HAP by Weight x [Density (lb)] x Gal Consumed x 1 ton (100) (gal) 2000 lb I. The amount of HAPs emitted monthly from all materials used. J. The amount of HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC emissions. [R307-401-8]

DAQE-AN104230018-24
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II.B.5 Conditions on Haul Roads II.B.5.a All roads and other operational areas that are used by mobile equipment shall be sprayed with
water to control fugitive dust. Treatment shall be applied of sufficient frequency and quantity to maintain the surface material in a condition such that fugitive emissions are minimized, unless the ambient temperature could result in freezing conditions. The opacity shall not exceed 20%
during all times of equipment operation. Records of water treatment shall be kept for all periods when the plant is in operation. The records shall include the following items:
A. Date, B. Number of treatments made,
C. Rainfall received, if any, and approximate amount, and
D. Time of day treatments were made.
Records of treatment shall be made available to the Director upon request and shall include a
period of five years ending with the date of the request. Records shall be maintained in accordance with Condition I.4 of this AO.

[R307-309]
II.B.5.b The owner/operator shall abide by a fugitive dust control plan acceptable to the Director for control of dust from haul roads. Monitoring Records of water applications shall serve as monitoring. Adherence to the most recently approved fugitive dust control plan shall be monitored to demonstrate that appropriate measures are being implemented to control fugitive dust. Recordkeeping Records of fugitive dust mitigation measures shall be kept for all periods. The records shall contain, at a minimum, the date and time of water applications, number of treatments made, dilution ratio, quantity applied, any rainfall received, and approximate amount. Records shall be maintained in accordance with Condition I.4 of this AO. [R307-309]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN104230017-16 dated October 24, 2016 Is Derived From NOI dated February 10, 2023 Incorporates Additional Information dated July 20, 2023 Incorporates Additional Information dated May 10, 2024

DAQE-AN104230018-24
Page 17

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-IN104230018-24

October 10, 2024

Joseph Eck
Interstate Brick Company
9780 South 5200 West
West Jordan, UT 84081-5625
[e-mail]

Dear Mr. Eck:

Re: Intent to Approve: Modification to Approval Order DAQE-AN104230017-16 to Account for
Existing Operations
Project Number: N104230018

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Salt Lake County Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — / H v A ? A C @ F w C A ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN104230018-24
Modification to Approval Order DAQE-AN104230017-16 to
Account for Existing Operations

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Interstate Brick Company - Brick Manufacturing Plant

Issued On
October 10, 2024

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — / H v A ? A C @ F w C A ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 16
ACRONYMS ............................................................................................................................... 17

DAQE-IN104230018-24
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GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Interstate Brick Company Interstate Brick Company - Brick Manufacturing Plant

Mailing Address Physical Address
9780 South 5200 West 9780 South 5200 West
West Jordan, UT 84081-5625 West Jordan, UT 84081-5625

Source Contact UTM Coordinates
Name: Greg Stevenson 413,500 m Easting
Phone: [phone],491,500 m Northing
Email: [e-mail] Datum NAD27
UTM Zone 12
SIC code 3251 (Brick & Structural Clay Tile)

SOURCE INFORMATION
General Description
Interstate Brick Company (ISB) operates a brick and tile manufacturing plant in West Jordan City, Salt
Lake County, Utah. The operation includes raw material (clays) storage, crushing/blending operations,
and three natural gas-fired kilns used to fire the products. Crushing and screen operations are controlled
with baghouses.

NSR Classification
Minor Modification at Major Source

Source Classification
Located in Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA
Salt Lake County
Airs Source Size: A

Applicable Federal Standards
Title V (Part 70) Major Source

DAQE-IN104230018-24
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Project Description
This modification includes:

1. The addition of emissions from crushing and screening as a result of baghouse vent reconfiguration.
Previously, on-site baghouses vented internally, causing hazardous indoor conditions. As a remediation to
internal dust issues, the baghouses will now vent out of the building. This change will result in an
increase in PM10 and PM2.5 emissions.

2. A reduction in NOx emissions. Reductions are based on 20+ years of emission testing on Kiln #3 and
Kiln #4. The new kiln lb/hr limits will be added (4.70 lb/hr for Kiln #3 and 6.40 lb/hr for Kiln #4). This
reduction will remove IBS from SIP consideration; testing for these kilns will be increased from every 5
years to every year.

3. Site-wide conditions were updated to comply with administrative standards and updates. There were no
changes to requirements as a result of these updates beyond the reduced NOx rates and increased
NOx-based stack testing frequency. Speed-related requirements were removed as emissions for hauling
are limited by the 20% opacity requirements for fugitive emissions.

4. ISB submitted a second notification for the inclusion of a replacement soda ash silo and controlling bin
vent. This project will be consolidated into the permit modification. The replacement silo and bin vent
will not increase total soda ash usage or expected emissions. The silos were labeled as "lime silos"
(II.A.7) in the existing AO. This label will be updated.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
Carbon Monoxide 0 219.48
Nitrogen Oxides -19.68 49.35
Particulate Matter - PM10 2.05 63.34
Particulate Matter - PM10 (Fugitives) 0 45.68
Particulate Matter - PM2.5 2.05 63.34
Sulfur Dioxide 0 69.00
Volatile Organic Compounds 0 14.87

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 14400
Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 0 13400
Organic HAPs (CAS #OHAPS) 0 8600
Change (TPY) Total (TPY)
Total HAPs 0 18.20

DAQE-IN104230018-24
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PUBLIC NOTICE STATEMENT
The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the intent to approve will be published in the Salt Lake Tribune and Deseret News on October 13, 2024. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring. [R307-150]
I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
DAQE-IN104230018-24
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SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT II.A.1 Brick and Tile Manufacturing Plant
II.A.2 Line #1 A. Tunnel Kiln #1 (not operational) II.A.3 Line #3 A. Line #3 kiln with packed tower scrubber and mist eliminator Scrubber air flow - 60,000 Actual Cubic Feet per Minute (ACFM) B. Line 3 baghouse - MikroPul
II.A.4 Line #4 A. Line #4 kiln Wet scrubber and mist eliminator Scrubber air flow - 89,800 ACFM B. Line #4 vacuum cleaner C. Line #4 shapes dryer D. Line #4 baghouse - MikroPul II.A.5 Grizzly Hopper
II.A.6 Primary and Secondary Crushers A. Primary crusher with baghouse Crusher manufacturer - Stedman Capacity: 100 tons per hour Control: Pulse jet baghouse Installed before August 31, 1983 B. Secondary crusher/grinding Installed before August 31, 1983 C. Screens Installed before August 31, 1983 II.A.7 Silos
Two soda ash silos Controlled by bin vent
II.A.8 Clay Storage Piles
DAQE-IN104230018-24
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II.A.9 Miscellaneous Diesel Equipment
II.A.10 Miscellaneous Equipment Extruder Vacuum Pumps, Storage Tanks, Vehicle Fueling Tanks, Space Heaters. This equipment is listed for informational purposes only.

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS II.B.1 Limitations and Test Procedures
II.B.1.a The following limitations shall not be exceeded: A. Plant wide production/consumption limits. 1) 2,880 tons raw clay consumption per rolling 24-hour period. 2) 393,236 tons of brick produced in Line #3 and Line #4 combined per rolling 12-month period. 3) 512,582 tons of brick produced plantwide per rolling 12-month period. B. Tunnel Kiln #1 (Not operational until scrubber is online) 13.62 tons of product per hour averaged over a rolling 24-hour period. C. Tunnel Kiln #3 17.92 tons of product per hour averaged over a rolling 24-hour period. D. Tunnel Kiln #4 26.97 tons of product per hour averaged over a rolling 24-hour period. E. Clay Prep for Line 3 not Including Kiln # 3 6,240 hours of operation per rolling 12-month period. F. Clay Prep for Line 4 not Including Kiln # 4 6,240 hours of operation per rolling 12-month period. To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of consumption, production, and/or hours of operation shall be kept for all periods when the plant is in operation. Production/consumption shall be determined by operator logs. The records of consumption/production shall be kept on a daily basis. Hours of operation shall be determined by monitoring and maintaining an operations log. [R307-401-8]
DAQE-IN104230018-24
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II.B.1.b Visible emissions from the following emission points shall not exceed the following values: A. All screens - 10% opacity. B. All conveyor transfer points - 10% opacity. C. All baghouses - 10% opacity. D. All buildings enclosing crushers - 10% opacity. . E. All crushers - 15%. F. All other points - 20% opacity. Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.c The owner/operator shall apply water to storage piles to maintain the opacity limits as required in
this AO. [R307-401-8]
II.B.1.d The owner/operator shall not operate Kiln #1 until the replacement scrubber for Kiln #1 has been approved in accordance with R307-401-8. [R307-401-8] II.B.1.e The owner/operator shall route all emissions from the primary crusher building through the
primary crusher baghouse prior to venting to the atmosphere. [R307-401-8]

II.B.1.f The owner/operator shall vent all process streams and exhaust air from Kiln #3 to a wet scrubber shall control process streams from Kiln #3 prior to venting to the atmosphere. [R307-401-8]
II.B.1.g The owner/operator shall vent all process streams and exhaust air from Kiln #4 through the wet scrubber prior to venting to the atmosphere. [R307-401-8]

DAQE-IN104230018-24
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II.B.1.h The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s): Scrubber Tunnel Kiln #3 NOx: 1-hr average 4.70 lb/hr PM10: 1-hr average 8.66 lb/hr PM2.5: 1-hr average 8.66 lb/hr SO2: 1-hr average 8.09 lb/hr Total Fluorides: 1-hr average 1.77 lb/hr Scrubber Tunnel Kiln #4 NOx: 1-hr average 6.40 lb/hr PM10: 1-hr average 3.97 lb/hr PM2.5: 1-hr average 3.97 lb/hr SO2: 1-hr average 5.87 lb/hr Total Fluorides: 1-hr average 3.25 lb/hr Line #3 Baghouse (dry filterable particulate only) PM10: 1-hr average 0.18 lb/hr Maximum Concentration 0.016 grains/dscf PM2.5: 1-hr average 0.18 lb/hr Maximum Concentration 0.016 grains/dscf Line #4 Baghouse (dry filterable particulate only) PM10: 1-hr average 0.34 lb/hr Maximum Concentration 0.016 grains/dscf PM2.5: 1-hr average 0.34 lb/hr Maximum Concentration 0.016 grains/dscf Primary Crusher Baghouse Vent (dry filterable particulate only) PM10: 1-hr average 0.56 lb/hr Maximum Concentration 0.010 grains/dscf PM2.5: 1-hr average 0.56 lb/hr Maximum Concentration 0.010 grains/dscf [R307-401-8]
II.B.1.h.1 To demonstrate compliance with the emission limitations above, the owner/operator shall
conduct emission testing (stack testing) as outlined below. [R307-401-8]
II.B.1.h.2 Test Frequency The owner/operator shall conduct subsequent PM10 and PM2.5 emission tests within five years after the date of the most recent emission test for all units. NOx emissions from Kiln #3 and Kiln #4 shall be tested annually. The Director may require the owner/operator to perform an emission test at any time. [R307-165-2, R307-401-8]
DAQE-IN104230018-24
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II.B.1.h.3 Notification At least 30 days prior to conducting an emission test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include: A. The date, time, and place of the proposed test. B. The proposed test methodologies. C. The stack to be tested. D. The procedures to be used. E. Any deviation from an EPA-approved test method. F. Explanation of any deviation from an EPA-approved test method. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-2, R307-401-8]
II.B.1.h.4 Testing The owner/operator shall conduct testing according to the approved source test protocol. The
Director may reject emission test data if the test did not follow the approved source test protocol
or if Director was not provided an opportunity to have an observer present at the test. [R307-165-5, R307-401-8]

II.B.1.h.5 Test Conditions The owner/operator shall conduct all tests while the source is operating at the maximum production or combustion rate at which the source will be operated unless otherwise specified in the approved source test protocol. During the tests, the owner/operator shall burn fuels or combinations of fuels, use raw materials, and maintain process conditions representative of normal operations. In addition, the owner/operator shall operate under any other relevant conditions that the Director specifies. [R307-165-4, R307-401-8] II.B.1.h.6 Standard Conditions & Emission Limit Parameters

A. Temperature - 68 degrees Fahrenheit (293 K).
B. Pressure - 29.92 in Hg (101.3 kPa).
C. Concentration (ppmdv) - 3% oxygen, dry basis.

D. Averaging Time - As specified in the applicable test method.
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.1.h.7 Reporting Within 60 days after completing an emission test, the owner/operator shall submit a copy of the test results to the Director. [R307-401-8]
II.B.1.i Test Methods
When performing emission testing, the owner/operator shall use the appropriate EPA-approved
test methods as acceptable to the Director. Acceptable test methods for pollutants are listed
below. [R307-401-8]

DAQE-IN104230018-24
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II.B.1.i.1 PM2.5 Total PM2.5 = Filterable PM2.5 + Condensable PM2.5 Filterable PM2.5 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM2.5. Condensable PM2.5 40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.1.i.2 PM10 Total PM10 = Filterable PM10 + Condensable PM10
Filterable PM10
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10
fraction of the filterable particulate
emissions, all of the filterable particulate emissions shall be considered PM10

Condensable PM10
40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to the Director.

Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or
other EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM10
fraction of the filterable particulate
emissions, all of the filterable particulate emissions shall be considered PM10
[R307-401-8]

II.B.1.i.3 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.1.i.4 SO2
40 CFR 60, Appendix A, Method 6 or 6C or other EPA-approved method as acceptable to the
Director. [R307-165]

II.B.1.i.5 Total Fluorines 40 CFR 60, Appendix A, Method 13B; 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow rate; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
DAQE-IN104230018-24
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II.B.1.j The moisture content of the clay shall be maintained at an average of no less than 4.0% by weight. The moisture content shall be tested if directed by the Director using the appropriate ASTM method. [R307-401-8] II.B.2 Fuels
II.B.2.a The owner/operator shall only use natural gas as fuel and propane as a backup fuel in the kilns. [R307-401-8] II.B.3 Monitoring - General Process
II.B.3.a The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the change in pressure of the gas stream through the baghouse and scrubbers. A. The minimum pressure drop in inches/w.g., for the baghouse and scrubbers shall be as follows: 1) Primary Crusher Baghouse with polyester felt 2.0 with PTFE membrane 0.4 2) Kiln 3 scrubber 0.1 3) Kiln 4 scrubber 2.0 The monitoring device must be certified by the manufacturer to be accurate within plus or minus five percent of the w.g. design measuring device and must be calibrated on an annual basis in accordance with the manufacturer's instructions. When the scrubber(s) are in operation, the pressure drop shall be within the limits specified above except during start-up and shut-down of the scrubber(s). When the primary crusher baghouse is in operation, the pressure drop shall be within the limits specified above, except during a period of ten crusher operating days following the filter media replacement. B. Monitoring Once per operating day for each scrubber, ISB shall verify that the differential pressure is within the permitted range. All pressure gauges shall be located such that an inspector/operator can safely read the indicator at any time. C. Record Keeping Results of the change in pressure shall be recorded on a daily basis. Continuous recording for the monitoring device is not required. [R307-401-8]
DAQE-IN104230018-24
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II.B.3.b The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the pH of the scrubbing solution of the gas stream through each scrubber. A. The pH range for the scrubbers shall be as follows: 1) Kiln 3 5-9 2) Kiln 4 5-9 The monitoring device must be certified by the manufacturer to be accurate within plus or minus five percent of the design pH and must be calibrated on an annual basis in accordance with the manufacturer's instructions. When the scrubber(s) are in operation, the pH shall be within the ranges specified above except during start-up and shut-down of the scrubber(s). B. Monitoring Once per operating day for each scrubber, ISB shall verify that the pH is within the permitted range. All meters shall be located such that an inspector/operator can safely read the indicator at any time. C. Record Keeping Results of the pH shall be recorded on a daily basis. Continuous recording for the monitoring device is not required. [R307-401-8]
II.B.3.c The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the flow rate of the scrubbing solution of the gas stream through
each scrubber.
A. The minimum scrubbing liquid flow rate in gallons per minute (gpm), for the scrubbers
shall be as follows:
1) Kiln 3 200

2) Kiln 4 600
The monitoring device must be certified by the manufacturer to be accurate within plus
or minus five percent of the design scrubbing liquid flow rate and must be calibrated on an annual basis in accordance with the manufacturer's instructions. When the scrubber(s)
are in operation, the scrubbing liquid flow rate shall be no less than the flow rates
specified above except during start-up and shut-down of the scrubber(s).
B. Monitoring
Once per operating day for each scrubber, ISB shall verify that the liquid flow rate
is within the permitted range. All flow gauges shall be located such that an
inspector/operator can safely read the indicator at any time.

C. Record Keeping
Results of the scrubbing liquid flow rate shall be recorded on a daily basis.
Continuous recording for the monitoring device is not required.

[R307-401-8]

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II.B.4 VOC and HAP Limitations II.B.4.a The plant-wide emissions of VOCs from the brick manufacturing plant and associated operations
shall not exceed 14.87 tons per rolling 12-month period for VOCs. Compliance with the limitation shall be determined on a rolling 12-month total. Based on the
twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months.
The VOC emissions shall be determined by maintaining a record of VOC-emitting materials used each month. The record shall include the following data for each material used:
A. Name of the VOC-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc.
B. Density of each material used (pounds per gallon).
C. Percent by weight of all VOC in each material used.
D. Gallons of each VOC-emitting material used.

E. The amount of VOC emitted monthly by each material used shall be calculated by the following procedure:

VOC = % VOC by Weight x [Density ( lb )] x Gal Consumed x 1 ton (100) (gal) 2000 lb

F. The amount of VOC emitted monthly from all materials used.
G. The amount of VOCs reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above to provide the monthly total VOC emissions.

[R307-401-8]
DAQE-IN104230018-24
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II.B.4.b The plant-wide emissions of HAPs from the brick manufacturing plant and associated operations shall not exceed: 7.2 tons per rolling 12-month period for HCl. 6.7 tons per rolling 12-month period for HF. 7.0 tons per rolling 12-month period for miscellaneous HAPs. 18.2 tons per rolling 12-month period for all HAPs combined. Compliance with the limitation shall be determined on a rolling 12-month total. Based on the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months. Compliance with HF and HCl limitations listed above shall be determined through a method of mass balance. The mass balance plan approved by the Director was submitted by ISB on October 22, 2009. If ISB submits any additional revised mass balance methods for determining annual emissions to the Director for approval, the plan shall include, at a minimum, the following: A. Proposed test methods and test frequency for determining the weight of the elemental fluorine contained in the clays used to manufacture brick. B. Proposed test methods and test frequency for determining the weight of the elemental fluorine contained in the finished product. C. Calculation method of determining emissions of HCL and HF, which will demonstrate compliance with the HCl and HF emission limitations listed above. The miscellaneous HAP emissions shall be determined by maintaining a record of HAP-emitting materials used each month. The record shall include the following data for each material used: D. Name of the HAP-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. E. Density of each material used (pounds per gallon). F. Percent by weight of all HAP in each material used. G. Gallons of each HAP-emitting material used. H. The amount of HAP emitted monthly by each material used shall be calculated by the following procedure: HAP = % HAP by Weight x [Density ( lb )] x Gal Consumed x 1 ton (100) (gal) 2000 lb I. The amount of HAPs emitted monthly from all materials used. J. The amount of HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC emissions. [R307-401-8]

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II.B.5 Conditions on Haul Roads II.B.5.a All roads and other operational areas that are used by mobile equipment shall be sprayed with
water to control fugitive dust. Treatment shall be applied of sufficient frequency and quantity to maintain the surface material in a condition such that fugitive emissions are minimized, unless the ambient temperature could result in freezing conditions. The opacity shall not exceed 20%
during all times of equipment operation. Records of water treatment shall be kept for all periods when the plant is in operation. The records shall include the following items:
A. Date; B. Number of treatments made;
C. Rainfall received, if any, and approximate amount; and
D. Time of day treatments were made.
Records of treatment shall be made available to the Director upon request and shall include a
period of five years ending with the date of the request. Records shall be maintained in accordance with Condition I.4 of this AO.

[R307-309]
II.B.5.b The owner/operator shall abide by a fugitive dust control plan acceptable to the Director for control of dust from haul roads. Monitoring: Records of water applications shall serve as monitoring. Adherence to the most recently approved fugitive dust control plan shall be monitored to demonstrate that appropriate measures are being implemented to control fugitive dust. Recordkeeping: Records of fugitive dust mitigation measures shall be kept for all periods. The records shall contain at a minimum: the date and time of water applications, number of treatments made, dilution ratio, quantity applied, any rainfall received and approximate amount. Records shall be maintained in accordance with Condition I.4 of this AO. [R307-309]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN104230017-16 dated October 24, 2016 Is Derived From NOI dated February 10, 2023 Incorporates Additional Information dated May 10, 2024 Incorporates Additional Information dated July 20, 2023

DAQE-IN104230018-24
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ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

The Salt Lake Tribune
Publication Name:
The Salt Lake Tribune
Publication URL:
Publication City and State:
Salt Lake City, UT
Publication County:
Salt Lake
Notice Popular Keyword Category:
Notice Keywords:
interstate brick company
Notice Authentication Number:
202410161246011909751
1761527914
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Notice Publish Date:
Sunday, October 13, 2024
Notice Content
NOTICE A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been
received for consideration by the Director: Company Name: Interstate Brick Company Location: Interstate Brick Company - Brick
Manufacturing Plant – 9780 South 5200 West, West Jordan, UT Project Description: Interstate Brick Company operates a brick and tile
manufacturing plant in West Jordan City, Salt Lake County, Utah. A modification was requested to reconfigure baghouse vents from internally
venting to externally venting. This change will increase PM10 and PM2.5 emissions. A new soda ash silo will be installed to replace an existing
silo. The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air
quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period.
The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same
address on or before November 12, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project.
Email comments will also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of
this notice, a hearing will be held in accordance with R307-401-7, UAC. Under Section 19-1-301.5, a person who wishes to challenge a
Permit Order may only raise an issue or argument during an adjudicatory proceeding that was raised during the public comment period and
was supported with sufficient information or documentation to enable the Director to fully consider the substance and significance of the
issue. Date of Notice: October 13, 2024 SLT0029799
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DAQE-NN104230018-24

October 10, 2024

Salt Lake Tribune and Deseret News
Legal Advertising Dept.
P.O. Box 704055
West Valley City, UT 84170
Acct #9001399880

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Salt Lake Tribune and
Deseret News on October 13, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Wasatch Front Regional Council
cc: Salt Lake County

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN104230018-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Interstate Brick Company
Location: Interstate Brick Company - Brick Manufacturing Plant – 9780 South 5200 West,
West Jordan, UT
Project Description: Interstate Brick Company operates a brick and tile manufacturing plant in West
Jordan City, Salt Lake County, Utah. A modification was requested to
reconfigure baghouse vents from internally venting to externally venting. This
change will increase PM10 and PM2.5 emissions. A new soda ash silo will be
installed to replace an existing silo.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before November 12, 2024, will be considered in
making the final decision on the approval/disapproval of the proposed project. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: October 13, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-MN104230018-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Dave Prey, Air Quality Modeler

DATE: October 9, 2023
SUBJECT: Modeling Analysis Review for the Notice of Intent Interstate Brick Company- Brick
Manufacturing Plant, Salt Lake County, Utah
_____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source.
I. OBJECTIVE
Interstate Brick Company (Applicant) is seeking a modified approval order for their Brick
Manufacturing Plant located in Salt Lake County, Utah. The operation includes raw materials
(clays) storage, crushing/blending operations, and three natural gas-fired kilns used to fire the
products. Crushing and screen operations are controlled with baghouses.

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility would be in compliance with State and Federal
concentration standards.

II. APPLICABLE RULE(S)

Utah Air Quality Rules:

R307-401-6 Condition for Issuing an Approval Order
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutants in Attainment Areas

III. MODELING METHODOLOGY

A. Applicability
Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. Total fugitive PM10
emissions were over 5 tons/year, so a modeling demonstration was performed to demonstrate
compliance with the NAAQS. Since the increase was less than 5 tons/year, modeling for PM10
was performed by the UDAQ.
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

DP
DP

00
DAQE-MN104230018-24
Page 2

B. Assumptions

1. Topography/Terrain

The Plant is at an elevation 4881 feet with few terrain features that have no affect on
concentration predictions.

a. Zone: 12

b. Approximate Location:
UTM (NAD83): 413805 meters East
4491415 meters North
2. Urban or Rural Area Designation

After a review of the appropriate 7.5 minute quadrangles, it was concluded the area is
“rural” for air modeling purposes.
3. Ambient Air

It was determined the Plant boundary used in the AQIA meets the State’s definition of
ambient air.

4. Building Downwash

The source was modeled with the AERMOD model. All structures at the plant were used in
the model to account for their influence on downwash.

5. Meteorology
Five (5) years of off-site surface and upper air data were used in the analysis consisting of
the following:

Surface – Salt Lake Airport, UT NWS: 2017-2021
Upper Air – Salt Lake Airport, UT NWS: 2017-2021

6. Background

The background concentrations were based on concentrations measured in Herriman, Utah.

7. Receptor and Terrain Elevations
The modeling domain used consisted of receptors including property boundary receptors.
This area of the state contains mountainous terrain and the modeling domain has simple and
complex terrain features in the near and far fields. Therefore, receptor points representing
actual terrain elevations from the area were used in the analysis.

DAQE-MN104230018-24
Page 3
8. Model and Options

The State-accepted AERMOD model was used to predict air pollutant concentrations under
a simple/complex terrain/wake effect situation. In quantifying concentrations, the
regulatory default option was selected.
9. Air Pollutant Emission Rates

Source
UTM Coordinates Modeled Emission Rates
Easting Northin
g PM10
(m) (m) (lb/hr) (tons/yr) hrs/year
FUGITIVE 413791 4491189 1.801
6 3.945 4380
KILN3 413805 4491415
8.660
0 37.931 8760
L3BH 413687 4491478 0.128
2 0.562 8760
KILN4 413737 4491877
3.970
0 17.389 8760
L4BH 413621 4491724 0.242
2 1.061 8760
CRUSHER 413563 4491539
0.560
0 2.453 8760

Total 15.36 63.34

10. Source Location and Parameters

Source Type
Source Parameters
Elev, Ht Tem
p Flow Dia Sigma
-Y
Sigma
-Z
X-
Dim
Y-
Dim Area
(ft) (m) (ft) (K) (m/s) (m) (m) (m) (m) (m) (m^2)
FUGITIVE
AREA_POL
Y 4894.8 0.9 3.0 0.00 3.00
299552.
7
KILN3 POINT 4881.0 16.8 55.0 319 9.46 1.49 0.00
L3BH POINT 4881.8 2.4 8.0 305
14.0
6 0.46 0.00
KILN4 POINT 4875.4 24.4 80.0 322 9.58 1.83 0.00
L4BH POINT 4878.0 1.2 4.0 303
19.7
0 0.46 0.00
CRUSHER POINT 4896.4 12.2 40.0 295 0.64 0.82 0.00

DAQE-MN104230018-24
Page 4
IV. RESULTS AND CONCLUSIONS

A. National Ambient Air Quality Standards

The below table provides a comparison of the predicted total air quality concentrations with the NAAQS. The predicted total concentrations are less than the NAAQS.

Pollutant Period
Prediction Others Background Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-Hour 14.87 0.00 116 130.9 150 87.2%

DP:jg

DAQE-

RN104230018 September 25, 2024 Joseph Eck
Interstate Brick Company 9780 South 5200 West West Jordan, UT 840815625
[e-mail] Dear Joseph Eck,
Re: Engineer Review: Modification to Approval Order DAQE-AN104230017-16 to Account for Existing Operations Project Number: N104230018 Please review and sign this letter and attached Engineer Review (ER) within 10 business days. For this document to be considered as the application for a Title V administrative amendment, a Title V Responsible Official must sign the next page. Please contact John Jenks at [phone] if you have any questions or concerns about the ER. If you accept the contents of this ER, please email this signed cover letter to John Jenks at [e-mail].
After receipt of the signed cover letter, the DAQ will prepare an Intent to Approve (ITA) for a 30-day public comment period. When the public comment period ends, the DAQ will consider any comments received and will issue the Approval Order. If you do not respond to this letter within 10 business days, the project will move forward without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue an Order prohibiting
construction. Approval Signature _____________________________________________________________
(Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 1
OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be considered as an application to administratively amend your Title V Permit, the Responsible Official, as
defined in R307-415-3, must sign the statement below. THIS IS STRICTLY OPTIONAL. If you do not want the Engineer Review to be considered as an application to administratively amend your Operating Permit only the approval signature above is required. Failure to have the Responsible Official sign below will not delay the Approval Order, but will require submittal of a separate Operating Permit Application to revise the Title V permit in accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document: Title V Operating Permit Application Due Dates clarifies the required due dates for Title V operating permit applications and can be viewed at:
https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality “Based on information and belief formed after reasonable inquiry, I certify that the statements and information provided for this Approval Order are true, accurate and complete and request that this Approval Order be considered as an application to administratively amend the Operating Permit.” Responsible Official _________________________________________________ (Signature & Date) Print Name of Responsible Official _____________________________________

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 2
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N104230018 Owner Name Interstate Brick Company
Mailing Address 9780 South 5200 West West Jordan, UT, 840815625
Source Name Interstate Brick Company- Brick Manufacturing Plant Source Location 9780 S. 5200 W. West Jordan, UT 84081-5625
UTM Projection 413,500 m Easting, 4,491,500 m Northing UTM Datum NAD27 UTM Zone UTM Zone 12 SIC Code 3251 (Brick & Structural Clay Tile) Source Contact Greg Stevenson Phone Number [phone] Email [e-mail] Billing Contact Gerry Gunning
Phone Number 8012805215 Email [e-mail]
Project Engineer John Jenks, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted February 6, 2023 Date of Accepted Application July 31, 2024

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 3
SOURCE DESCRIPTION General Description
Interstate Brick Company (ISB) operates a brick and tile manufacturing plant in West Jordan City, Salt Lake County, Utah. The operation includes raw materials (clays) storage, crushing/blending operations, and three natural gas-fired kilns used to fire the products. Crushing
and screen operations are controlled with baghouses. NSR Classification: Minor Modification at Major Source Source Classification Located in: Salt Lake City UT PM2.5 NAA, Salt Lake County SO2 NAA, Salt Lake County Airs Source Size: A
Applicable Federal Standards Title V (Part 70) Major Source
Project Proposal Modification to Approval Order DAQE-AN104230017-16 to Account for Existing Operations
Project Description This modification includes: 1. The addition of emissions from crushing and screening as a result of baghouse vent reconfiguration. Previously on-site baghouses vented internally causing hazardous indoor conditions. As a remediation to internal dust issues, the baghouses will now vent out of the building. This change will result in an increase in PM10 and PM2.5 emissions.
2. A reduction in NOx emissions. Reductions are based on 20+ years of emission testing on Kiln #3 and Kiln #4. The new kiln lb/hr limits will be added (4.70 lb/hr for Kiln #3, and 6.40 lb/hr for Kiln #4). This reduction will remove IBS from SIP consideration, testing for these kilns will be increased form every 5 years to every year. 3. Site-wide conditions were updated to comply with administrative standards and updates. There were no changes to requirements as a result of these updates beyond the reduced NOx rates and
increased NOx-based stack testing frequency. Speed related requirements were removed as emissions for hauling are limited by the 20% opacity requirements for fugitive emissions.
4. Interstate Brick submitted a second notification for the inclusion of a replacement soda ash silo and controlling bin vent. This project will be consolidated into the permit modification. The replacement silo and bin vent will not increase total soda ash usage or expected emissions. The
silos were labeled as "lime silos" (II.A.7) in the existing AO. This label will be updated. EMISSION IMPACT ANALYSIS
The emission changes in this modification are below modeling thresholds and do not trigger the requirement for a modeling analysis under R307-410-4 and R307-410-5, modeling is not required. [Last updated September 20, 2024]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 4
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) Carbon Monoxide 0 219.48 Nitrogen Oxides -19.68 49.35
Particulate Matter - PM10 2.05 63.34
Particulate Matter - PM10 (Fugitives) 0 45.68
Particulate Matter - PM2.5 2.05 63.34
Sulfur Dioxide 0 69.00
Volatile Organic Compounds 0 6.86 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 14400
Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 0 13400
Organic HAPs (CAS #OHAPS) 0 8600
Change (TPY) Total (TPY)
Total HAPs 0 18.20 Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 5
Review of BACT for New/Modified Emission Units 1. BACT review regarding new baghouse system
As a result of rerouting the baghouses from an internal venting configuration to an external venting configuration, PM10 and PM2.5 emissions will increase. The total increase is 2.09 tpy PM10 and PM2.5. The PM10 and PM2.5 are controlled through use of baghouses that are considered the most
effective add-on control option for particulate emissions. BACT for this operation is proper maintenance and operation of the baghouses and a visible emissions limit at or below 10% opacity. [Last updated September 20, 2024]
SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the five-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five (5) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with R307-150 Series. Inventories, Testing and Monitoring.
[R307-150] I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 6

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Brick and Tile Manufacturing Plant
II.A.2 Line #1 A. Tunnel Kiln #1 (not operational)
II.A.3 Line #3 A. Line #3 kiln with packed tower scrubber and mist eliminator
Scrubber air flow - 60,000 Actual Cubic Feet per Minute (ACFM) B. Line 3 baghouse - MikroPul II.A.4 Line #4
A. Line #4 kiln
Wet scrubber and mist eliminator
Scrubber air flow - 89,800 ACFM
B. Line #4 vacuum cleaner C. Line #4 shapes dryer D. Line #4 baghouse - MikroPul
II.A.5 Grizzly Hopper II.A.6 Primary and Secondary Crushers A. Primary crusher with baghouse Crusher manufacturer - Stedman Capacity: 100 tons per hour
Control: Pulse jet baghouse Installed before August 31, 1983 B. Secondary crusher/grinding
Installed before August 31, 1983 C. Screens Installed before August 31, 1983
II.A.7 Silos Two soda ash silos Controlled by bin vent

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 7
II.A.8 Clay Storage Piles
II.A.9 Miscellaneous Diesel Equipment
II.A.10 Miscellaneous Equipment Extruder Vacuum Pumps, Storage Tanks, Vehicle Fueling Tanks, Space Heaters.
This equipment is listed for informational purposes only.

SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Limitations and Test Procedures

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 8
II.B.1.a The following limitations shall not be exceeded: A. Plant wide production/consumption limits

1) 2,880 tons raw clay consumption per rolling 24-hour period.
2) 393,236 tons of brick produced in Line #3 and Line #4 combined per
rolling 12-month period.

3) 512,582 tons of brick produced plantwide per rolling 12-month period. B. Tunnel Kiln #1 (Not operational until scrubber is online)
13.62 tons of product per hour averaged over a rolling 24-hour period. C. Tunnel Kiln #3
17.92 tons of product per hour averaged over a rolling 24-hour period.
D. Tunnel Kiln #4

26.97 tons of product per hour averaged over a rolling 24-hour period.
E. Clay Prep for Line 3 not Including Kiln # 3
6,240 hours of operation per rolling 12-month period. F. Clay Prep for Line 4 not Including Kiln # 4
6,240 hours of operation per rolling 12-month period.
To determine compliance with a rolling 12-month total the owner/operator shall calculate a new 12-month total by the twentieth day of each month using data from the previous 12 months. Records of consumption, production and or hours of operation shall be kept for all
periods when the plant is in operation. Production/consumption shall be determined by operator logs. The records of consumption/production shall be kept on a daily basis. Hours of operation shall be determined by monitoring and maintaining an operations log. [R307-401-8]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 9
II.B.1.b Visible emissions from the following emission points shall not exceed the following values:
A. All screens - 10% opacity
B. All conveyor transfer points - 10% opacity C. All baghouses - 10% opacity D. All buildings enclosing crushers - 10% opacity E. All crushers - 15% F. All other points - 20% opacity
Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.c The owner/operator shall apply water to storage piles to maintain the opacity limits as required in this AO. [R307-401-8]
II.B.1.d The owner/operator shall not operate Kiln #1 until the replacement scrubber for Kiln #1 has been approved in accordance with R307-401-8. [R307-401-8]
II.B.1.e NEW The owner/operator shall route all emissions from the primary crusher building through the primary crusher baghouse prior to venting to the atmosphere. [R307-401-8] II.B.1.f The owner/operator shall vent all process streams and exhaust air from Kiln #3 to a wet scrubber shall control process streams from Kiln #3 prior to venting to the atmosphere. [R307-401-8]

II.B.1.g The owner/operator shall vent all process streams and exhaust air from Kiln #4 through the wet scrubber prior to venting to the atmosphere. [R307-401-8]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 10
II.B.1.h The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s): Scrubber Tunnel Kiln #3 NOx: 1-hr average 4.70 lb/hr PM10: 1-hr average 8.66 lb/hr PM2.5: 1-hr average 8.66 lb/hr SO2: 1-hr average 8.09 lb/hr Total Fluorides: 1-hr average 1.77 lb/hr
Scrubber Tunnel Kiln #4 NOx: 1-hr average 6.40 lb/hr PM10: 1-hr average 3.97 lb/hr PM2.5: 1-hr average 3.97 lb/hr
SO2: 1-hr average 5.87 lb/hr Total Fluorides: 1-hr average 3.25 lb/hr Line #3 Baghouse (dry filterable particulate only) PM10: 1-hr average 0.18 lb/hr
Maximum Concentration 0.016 grains/dscf PM2.5: 1-hr average 0.18 lb/hr Maximum Concentration 0.016 grains/dscf
Line #4 Baghouse (dry filterable particulate only)
PM10: 1-hr average 0.34 lb/hr Maximum Concentration 0.016 grains/dscf PM2.5: 1-hr average 0.34 lb/hr
Maximum Concentration 0.016 grains/dscf
Primary Crusher Baghouse Vent (dry filterable particulate only) PM10: 1-hr average 0.56 lb/hr Maximum Concentration 0.010 grains/dscf PM2.5: 1-hr average 0.56 lb/hr Maximum Concentration 0.010 grains/dscf. [R307-401-8]
II.B.1.h.1 To demonstrate compliance with the emission limitations above, the owner/operator shall conduct emission testing (stack testing) as outlined below. [R307-401-8]

II.B.1.h.2 Test Frequency The owner/operator shall conduct subsequent PM10 and PM2.5 emission tests within five years after the date of the most recent emission test for all units. NOx emissions from Kiln #3 and
Kiln #4 shall be tested annually. The Director may require the owner/operator to perform an emission test at any time. [R307-165-2, R307-401-8]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 11
II.B.1.h.3 Notification
At least 30 days prior to conducting an emission test, the owner/operator shall submit a source
test protocol to the Director. The source test protocol shall include: A. The date, time, and place of the proposed test B. The proposed test methodologies C. The stack to be tested D. The procedures to be used E. Any deviation from an EPA-approved test method
F. Explanation of any deviation from an EPA-approved test method
If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-2, R307-401-8]
II.B.1.h.4 Testing The owner/operator shall conduct testing according to the approved source test protocol. The Director may reject emission test data if the test did not follow the approved source test protocol or if Director was not provided an opportunity to have an observer present at the test. [R307-165-5, R307-401-8]
II.B.1.h.5 Test Conditions
The owner/operator shall conduct all tests while the source is operating at the maximum production or combustion rate at which the source will be operated unless otherwise specified in the approved source test protocol. During the tests, the owner/operator shall burn fuels or combinations of fuels, use raw materials, and maintain process conditions representative of normal operations. In addition, the owner/operator shall operate under any other relevant conditions that the Director specifies. [R307-165-4, R307-401-8]
II.B.1.h.6 Standard Conditions & Emission Limit Parameters A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Concentration (ppmdv) - 3% oxygen, dry basis D. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
II.B.1.h.7 Reporting Within 60 days after completing an emission test, the owner/operator shall submit a copy of the test results to the Director. [R307-401-8]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 12
II.B.1.i Test Methods
When performing emission testing, the owner/operator shall use the appropriate EPA-
approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
II.B.1.i.1 PM2.5
Total PM2.5 = Filterable PM2.5 + Condensable PM2.5 Filterable PM2.5 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM2.5.
Condensable PM2.5 40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.1.i.2 PM10 Total PM10 = Filterable PM10 + Condensable PM10 Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10 fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10
.
Condensable PM10 40 CFR 51, Appendix M, Method 202 or other EPA-approved testing method as acceptable to the Director. Filterable PM10 40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201; Method 201A; or other EPA-approved testing method as acceptable to the Director. If other approved testing methods are used which cannot measure the PM10
fraction of the filterable particulate emissions, all of the filterable particulate emissions shall be considered PM10 [R307-401-8] II.B.1.i.3 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 13
II.B.1.i.4 NEW SO2
40 CFR 60, Appendix A, Method 6 or 6C or other EPA-approved method as acceptable to the
Director. [R307-165] II.B.1.i.5 Total Fluorines 40 CFR 60, Appendix A, Method 13B; 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric flow rate; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.1.j The moisture content of the clay shall be maintained at an average of no less than 4.0% by weight. The moisture content shall be tested if directed by the Director using the appropriate ASTM method. [R307-401-8] II.B.2 Fuels II.B.2.a The owner/operator shall only use natural gas as a fuel and propane as a backup fuel in the kilns. [R307-401-8]
II.B.3 Monitoring - General Process

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 14
II.B.3.a The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the change in pressure of the gas stream through the baghouse and scrubbers.
A. The minimum pressure drop in inches/w.g., for the baghouse and scrubbers
shall be as follows:

1) Primary crusher baghouse
with polyester felt 2.0
with PTFE membrane 0.4
2) Kiln 3 scrubber 0.1
3) Kiln 4 scrubber 2.0
The monitoring device must be certified by the manufacturer to be accurate within
plus or minus five percent of the w.g. design measuring device and must be calibrated
on an annual basis in accordance with the manufacturer's instructions. When the
scrubber(s) are in operation, the pressure drop shall be within the limits specified
above except during start-up and shut-down of the scrubber(s). When the primary
crusher baghouse is in operation, the pressure drop shall be within the limits
specified above, except during a period of ten crusher operating days following the
filter media replacement. B. Monitoring
Once per operating day for each scrubber, ISB shall verify that the differential
pressure is within the permitted range. All pressure gauges shall be located such
that an inspector/operator can safely read the indicator at any time.
C. Record Keeping

Results of the change in pressure shall be recorded on a daily basis. Continuous
recording for the monitoring device is not required. [R307-401-8]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 15
II.B.3.b The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the pH of the scrubbing solution of the gas stream through each scrubber.
A. The pH range for the scrubbers shall be as follows:
1) Kiln 3 5-9
2) Kiln 4 5-9
The monitoring device must be certified by the manufacturer to be accurate within
plus or minus five percent of the design pH and must be calibrated on an annual
basis in accordance with the manufacturer's instructions. When the scrubber(s)
are in operation, the pH shall be within the ranges specified above except during
start-up and shut-down of the scrubber(s). B. Monitoring
Once per operating day for each scrubber, ISB shall verify that the pH is within
the permitted range. All meters shall be located such that an inspector/operator
can safely read the indicator at any time.
C. Record Keeping

Results of the pH shall be recorded on a daily basis. Continuous recording for
the monitoring device is not required. [R307-401-8]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 16
II.B.3.c The owner/operator shall install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the flow rate of the scrubbing solution of the gas stream through each scrubber.
A. The minimum scrubbing liquid flow rate in gallons per minute (gpm), for the scrubbers shall be as follows:
1) Kiln 3 200
2) Kiln 4 600 The monitoring device must be certified by the manufacturer to be accurate within plus or minus five percent of the design scrubbing liquid flow rate and must be
calibrated on an annual basis in accordance with the manufacturer's instructions. When the scrubber(s) are in operation, the scrubbing liquid flow rate shall be no less than the flow rates specified above except during start-up and shut-down of the scrubber(s). B. Monitoring
Once per operating day for each scrubber, ISB shall verify that the liquid flow rate is within the permitted range. All flow gauges shall be located such that an inspector/operator can safely read the indicator at any time. C. Record Keeping Results of the scrubbing liquid flow rate shall be recorded on a daily basis. Continuous recording for the monitoring device is not required. [R307-401-8]
II.B.4 VOC and HAP Limitations

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 17
II.B.4.a The plant-wide emissions of VOCs from the brick manufacturing plant and associated operations shall not exceed 14.87 tons per rolling 12-month period for VOCs. Compliance with the limitation shall be determined on a rolling 12-month total. Based on the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months.
The VOC emissions shall be determined by maintaining a record of VOC-emitting materials
used each month. The record shall include the following data for each material used: A. Name of the VOC-emitting material, such as: paint, adhesive, solvent, thinner,
reducers, chemical compounds, toxics, isocyanates, etc. B. Density of each material used (pounds per gallon) C. Percent by weight of all VOC in each material used
D. Gallons of each VOC-emitting material used
E. The amount of VOC emitted monthly by each material used shall be calculated by
the following procedure:

VOC = % VOC by Weight x [Density ( lb )] x Gal Consumed x 1 ton
(100) (gal) 2000 lb F. The amount of VOC emitted monthly from all materials used. G. The amount of VOCs reclaimed for the month shall be similarly quantified and
subtracted from the quantities calculated above to provide the monthly total
VOC emissions. [R307-401-8]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 18
II.B.4.b The plant-wide emissions of HAPs from the brick manufacturing plant and associated operations shall not exceed: 7.2 tons per rolling 12-month period for HCl 6.7 tons per rolling 12-month period for HF 7.0 tons per rolling 12-month period for miscellaneous HAPs 18.2 tons per rolling 12-month period for all HAPs combined Compliance with the limitation shall be determined on a rolling 12-month total. Based on the twentieth day of each month, a new 12-month total shall be calculated using data from the previous 12 months.
Compliance with HF and HCl limitations listed above shall be determined through a method
of mass balance. The mass balance plan approved by the Director was submitted by ISB on October 22, 2009. If ISB submits any additional revised mass balance methods for determining annual emissions to the Director for approval, the plan shall include, at a minimum, the following:
A. Proposed test methods and test frequency for determining the weight of the elemental fluorine contained in the clays used to manufacture brick B. Proposed test methods and test frequency for determining the weight of the elemental fluorine contained in the finished product C. Calculation method of determining emissions of HCL and HF which will demonstrate compliance with the HCl and HF emission limitations listed above. The miscellaneous HAP emissions shall be determined by maintaining a record of HAP-emitting materials used each month. The record shall include the following data for each material used: D. Name of the HAP-emitting material, such as: paint, adhesive, solvent, thinner, reducers, chemical compounds, toxics, isocyanates, etc. E. Density of each material used (pounds per gallon) F. Percent by weight of all HAP in each material used G. Gallons of each HAP-emitting material used
H. The amount of HAP emitted monthly by each material used shall be calculated by
the following procedure: HAP = % HAP by Weight x [Density ( lb )] x Gal Consumed x 1 ton (100) (gal) 2000 lb I. The amount of HAPs emitted monthly from all materials used. J. The amount of HAPs reclaimed for the month shall be similarly quantified and subtracted from the quantities calculated above to provide the monthly total VOC emissions. [R307-401-8]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 19
II.B.5 Conditions on Haul Roads
II.B.5.a All roads and other operational areas that are used by mobile equipment shall be sprayed with water to control fugitive dust. Treatment shall be applied of sufficient frequency and quantity to maintain the surface material in a condition such that fugitive emissions are minimized, unless the ambient temperature could result in freezing conditions. The opacity shall not exceed 20% during all times of equipment operation. Records of water treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: A. Date; B. Number of treatments made;
C. Rainfall received, if any, and approximate amount; and D. Time of day treatments were made. Records of treatment shall be made available to the Director upon request and shall include a period of five years ending with the date of the request. Records shall be maintained in
accordance with Condition I.4 of this AO. [R307-309] II.B.5.b The owner/operator shall abide by a fugitive dust control plan acceptable to the Director for control of dust from haul roads. Monitoring: Records of water applications shall serve as monitoring. Adherence to the most recently approved fugitive dust control plan shall be monitored to demonstrate that appropriate measures are being implemented to control fugitive dust.
Recordkeeping:
Records of fugitive dust mitigation measures shall be kept for all periods. The records shall
contain at a minimum: the date and time of water applications, number of treatments made, dilution ratio, quantity applied, any rainfall received and approximate amount. Records shall be maintained in accordance with Condition I.4 of this AO. [R307-309]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 20
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes DAQE-AN104230017-16 dated October 24, 2016
Is Derived From NOI dated March 23, 2023 Incorporates Additional Information dated May 10, 2024 Incorporates Additional Information dated July 20, 2023
REVIEWER COMMENTS
1. Comment regarding emission estimates: The emissions as a result of venting the baghouses externally were calculated using the exhaust point from the baghouse. Baghouse assumptions included: 26,557 CFM exhaust, 6240 operational hours per year, and a 97% control on PM10 and PM2.5 emission rates (0.53 lb/ton PM10 and 0.0032 lbs / ton per Ap-42 Table 11.3-2) No change in emissions from the new soda ash silo is expected. [Last updated September 4, 2024] 2. Comment regarding emissions testing for 50 TPY Major Source Status:
The source proposed a NOx reduction based on Kiln #3 and Kiln #4 testing results. The proposal reduces site wide NOx to 49.35 tons per year of NOx. To ensure compliance with this value, yearly stack testing for NOx emissions was added. [Last updated September 4, 2024] 3. Comment regarding change in equipment list: The source requested the installation of a replacement soda ash silo. The replacement silo would not result in a change in emissions. The soda ash silos were also incorrectly listed as lime silos in the previous AO. This has been corrected. [Last updated September 4, 2024]
4. Comment regarding Tunnel Kiln #1: This unit is non-operational but remains in the equipment list as a placeholder. Should ISB wish to
restart this unit, a new NOI will be required which includes the use of new control equipment. [Last updated September 25, 2024]

Engineer Review N104230018: Interstate Brick Company- Brick Manufacturing Plant September 25, 2024 Page 21
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
© 2023 Maul Foster & Alongi, Inc.
July 20, 2023
Project No. M1469.01.002
Ana Williams
Utah Department of Environmental Quality
Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84114
Re: Interstate Brick NOI – Proposed NOX Emission Limit Revisions
Dear Ana Williams:
Interstate Brick Company (ISB) is submitting this Notice of Intent (NOI) in order to reduce the NOX
permit limits currently shown in Approval Order DAQE-AN104230017-17 (AO) and Title V permit
3500200001 (Title V). ISB requested that Maul Foster & Alongi, Inc. (MFA) assist them with the
process of reducing the permitted NOX emission rates in advance of the forthcoming Ozone Serious
Nonattainment State Implementation Plan (Serious SIP) development process. Based on
communication with the Utah Division of Air Quality (DAQ), the major source threshold for NOX and
VOC (both precursors to ozone formation) will be lowered to 50 tons per year (tons/yr) as part of the
Serious SIP. ISB wishes to revise their permitted emission limits to demonstrate that annual
emissions of NOX will not exceed 50 tons/yr (ISB VOC emissions are already below 50 tons/yr). As a
result, ISB will not be a named source in the Serious SIP.
The following letter outlines the basis for the requested permit limit revisions.
RECENT REGULATORY BACKGROUND
The Northern Wasatch Front (within which ISB is located) was designated as moderate
nonattainment for ozone on November 7, 2022, with a requirement to attain the ozone standard by
August 3, 2024. Recent monitoring data indicates that the Northern Wasatch Front airshed will not
attain the standard by the required date, and will be reclassified to serious nonattainment in
February of 2025. The major source threshold in the Serious Nonattainment Area will be lowered to
50 tons/yr for ozone precursors, which include both NOX and VOC.
In 2016, ISB applied for, and obtained, revisions to their previous Approval Order demonstrating that
the facility had potential emissions of NOX below the 70 tons/yr PM2.5 major source threshold, which
precluded ISB from becoming a named source in the PM2.5 Serious SIP process.
There have been no modifications to the facility that affect emissions since the issuance of the AO in
2016. The Line 1 Kiln is still non-operational and cannot be operated until a new wet scrubber is
permitted and installed. However, the permitted emission limits include a level of conservatism that
can be adjusted, as outlined in the following sections.
6 Centerpointe Drive, Suite 360 | Lake Oswego, OR 97035 | 971 713 3590 | www.maulfoster.com
Ana Williams Project No. M1469.01.002
July 20, 2023 Page 2
© 2023 Maul Foster & Alongi, Inc.
Basis of Permitted Emission Limit Revision
ISB is requesting a revision to the NOX emission limits for Kiln 3 and Kiln 4 to ensure that the facility
is not a major source and should not be a named source under the Ozone Serious SIP.
Table 1 shows the historical source test results, and the proposed emission limits derived from the
source test results. The proposed emission limits were calculated by scaling up the maximum of the
tested emission rates shown in Table 1 by 23% to account for potential short-term variability that
may occur during testing campaigns.
Table 1: Summary of Source Test Results
Test ID Year
NOX Outlet Emissions
(lb/hr)
Kiln 3 Kiln 4
2021-1831 2021 1.90 2.50
2018-0847D 2018 1.20 3.80
ISB5070 2015 0.40 3.20
ISB0070 2010 0.30 2.50
ISB5219 2005 3.80 5.20
ISB0368 (1) 2000 2.40 --
Average - All Years 1.67 3.44
Maximum - All Years 3.80 5.20
Proposed Permit Limit (2) 4.70 6.40
Current Permit Limit 5.07 10.52
References:
(1)Kiln 4 was upgraded in 2004, source tests conducted before and during this period are not representative of current
Kiln 4 operation.
(2) Proposed permit limit represents the maximum of all source test values scaled up 23% to account for potential short-
term variability in source test results.
Emission calculations in Table 2 demonstrate that annual facility NOX PTE based on the proposed
permit limits is below 50 tons/yr. As shown in Table 2, Kiln 3 and Kiln 4 are the primary contributors
to the NOX PTE at ISB. For purposes of comparison to the major source threshold, PTE excludes
fugitive, mobile, and insignificant emission sources, as defined in Utah Administrative Code R307-
101.
Table 2: Permitted Emission Rates
Source
Current Permitted NOX
Emissions Proposed NOX Emissions
Hourly
(lb/hr)
Annual
(tons/yr)
Hourly
(lb/hr)
Annual
(tons/yr)
Kiln 3 5.07 22.23 (a)4.70 20.59 (a)
Kiln 4 10.52 46.07 (a)6.40 28.03 (a)
Other: Line 4 Shapes Dryer -- 0.73 -- 0.73
Total Facility Permitted PTE -- 69.03 -- 49.35
Notes:
(a) Annual potential to emit (tons/yr) = (hourly potential to emit [lb/hr]) x (8,760 hrs/yr) x (ton/2,000 lb)
Ana Williams Project No. M1469.01.002
July 20, 2023 Page 3
The Line 4 Shapes Dryer represents an additional source that contributes to the annual NOX
stationary source emissions. It is a natural gas-fired dryer with a maximum annual throughput of
14,888 tons per year. Emissions are based on the NOX emission factor for “brick dryer with
supplemental gas burner” in AP-42 Table 11.3-3 (0.098 lb NOX/ton). No changes to this source are
proposed as part of this NOI.
Revised NOX Emission Limits
As shown in Table 2, the proposed NOX emission limits result in annual emissions of 20.59 tons NOX
for Kiln 3, and 28.03 tons NOX for Kiln 4. This is in contrast to the current permitted short term NOX
emission limits which, when assessed over a full year (24 hours per day, 365 days per year), result in
a PTE of 22.2. tons NOX/yr for kiln 3, and 46.07 tons NOX/yr for Kiln 4.
The revised short-term emission limits reduce the overall facility NOX PTE by 19.7 tons/yr, and result
in an overall facility NOX PTE of 49.35 tons/yr.
Based on the discussion above, and the calculations provided in Table 2, ISB requests that the
permitted NOX emission limits be revised to the following:
Kiln 3 = 4.7 lb NOX/hr (AO Section II.B.1.g/Title V Section II.B.2.b)
Kiln 4 = 6.4 lb NOX/hr (AO Section II.B.1.g/Title V Section II.B.3.b)
Facility PTE = 49.35 tons NOX/yr (AO Abstract)
The proposed facility PTE shown above includes emissions from the other sources contributing to the
facility PTE for NOX.
ISB also acknowledges that NOX testing on the outlet of the Kiln 3 and Kiln 4 scrubbers will need to
be performed every year. Both the AO (Section II.B.1.g.A(1)) and Title V operating permit (Sections
II.B.2.b.1 and II.B.3.b.1) should be updated accordingly.
Facility Production Flexibility
ISB is only requesting a revision to the NOX emission limits. Due to potential future production
demands, ISB is not requesting an across-the-board revision to current permitted emission rates or
production rates. ISB is dependent upon the ability to maintain flexibility in their production lines to
meet potential future demand as economic recovery becomes a reality, particularly in the
challenging regulatory environment of Salt Lake County.
Due to the current nonattainment status of the airshed with respect to both ozone and PM2.5, ISB
requests that the emission limits for all other pollutants be retained at their current levels. ISB
understands that all future projects considered at the facility will need to go through the Notice of
Intent process.
CONCLUSION
ISB wishes to modify the permitted short term and annual NOX emission limits based on the
information provided in this letter. ISB wishes to hold all other permitted emission rates constant in
anticipation of needing to utilize additional capacity for new product lines in the future.
© 2023 Maul Foster & Alongi, Inc.
Ana Williams Project No. M1469.01.002
July 20, 2023 Page 4
© 2023 Maul Foster & Alongi, Inc.
Sincerely,
Maul Foster & Alongi, Inc.
Brian Eagle
Senior Air Quality Consultant
cc: Greg Stevenson (Basalite)
Travis DuVall (Interstate Brick)
Joe Eck (Interstate Brick)
© 2023 Maul Foster & Alongi, Inc.
Limitations
The services undertaken in completing this report were performed consistent with generally
accepted professional consulting principles and practices. No other warranty, express or implied, is
made. These services were performed consistent with our agreement with our client. This report is
solely for the use and information of our client unless otherwise noted. Any reliance on this report by
a third party is at such party’s sole risk.
Opinions and recommendations contained in this report apply to conditions existing when services
were performed and are intended only for the client, purposes, locations, time frames, and project
parameters indicated. We are not responsible for the impacts of any changes in environmental
standards, practices, or regulations subsequent to performance of services. We do not warrant the
accuracy of information supplied by others, or the use of segregated portions of this report.
Kiln 3 lb/hr Kiln 4 lb/hr
Proposed Permit Limit (2)4.7 6.4
Current Permit Limit 5.07 10.52
Previous 22.2066 46.0776 68.2842
Proposed NOx 20.586 28.032 48.618
Not accounted for:
Miscellaneous disel equipment
Heaters/boilers
1/2/24, 5:51 PM State of Utah Mail - Interstate Brick - NOI For the Dust Collectors.
https://mail.google.com/mail/u/0/?ik=b363bbe9c3&view=pt&search=all&permmsgid=msg-f:1757948863517718839&simpl=msg-f:1757948863517718839 1/1
Sarah Foran <[e-mail]>
Interstate Brick - NOI For the Dust Collectors.
Gregory Stevenson <[e-mail]>Wed, Feb 15, 2023 at 6:24 PM
To: Sarah Foran <[e-mail]>
Cc: Joe Eck <[e-mail]>, John Jenks <[e-mail]>
Hi Sarah.
Before I go on vacation I thought I should answer this. The Current EI has the primary crusher
included. It’s a 100 tph Stedman that has it’s own baghouse that is stack tested for PM triennially.
It’s in a different building and feeds the secondary crusher with a conveyor.

We want to vent two big Mikropul baghouses inside the Secondary crusher building to the outside
so they don’t create a hurricane in the building. That’s all. Unfortunately, because I can’t find
anywhere that the secondary crusher has a PTE or is included in an emissions inventory. I think we
have to add it. I can add some more info about the fact that once the dust collectors are operating,
with the attenuation effect of the building they are in, the additional emissions will be very small. I’ll
calculate it out but the total increase is in the range of 1.5 tpa.
It’s pretty good considering that this is the biggest PM source on-site.
Hope this helps.
[Quoted text hidden]
[Quoted text hidden]
Utah Division of Air Quality
New Source Review Section
Form 10
Company Interstate
Source Secondary Crusher / Grinding
Date __2023-02-08____
Fabric Filters (Baghouses)
Baghouse Description
1. Briefly describe the process controlled by this baghouse:
Gas Stream Characteristics
2. Flow Rate (acfm):4. Particulate Loading (grain/scf)
Design Max Average
Expected
3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __TBD___ Low __TBD__
6. Gas Stream Temperature (°F):7. Fan Requirements (hp) (ft
3/min)
Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.)12. Number of Bags:13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□Nomex nylon
□Polyester
□Acrylics
□Fiber glass
□Cotton
□Teflon
□___________
14. Filtering
Efficiency
Rating:
_ ___%
15.Air to Cloth
Ratio:
______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□Reverse Air □ Shaker
□Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Two Mikro Pul 80F4 Cloth Bag Dust Collectors service multiple pickup points located throughout the
Secondary Crusher / Grinding building. PM that is currently uncontrolled will be collected and vented fromThe building by exhaust ducting.
28,454 26,557 Dry
Ambient
x 320 per Collector8 Feet
8.6
4 5/8 inches
75 HP 26,557 CFM
Velocity 4,200 FPM
0.14 gr/scf 0.00084 gr/scf
Per Dust Collector (Per AP-42) PM10
24
6240 xGT 99.9
0.191 0.597
NA NA
NA NA
NA
ND ND
NA NA
NA NA
Page 2 of 2
Instructions - Form 10 Fabric Filters (Baghouses)
NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2.Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in
filling out this form. Ask to speak with a New Source Review engineer. We will be glad to
help!
1.Describe the process equipment that the filter controls, what product is being controlled, particle size
data (if available), i.e., cement silo, grain silo, nuisance dust in work place, process control with high
dust potential, etc.
2.The maximum and design exhaust gas flow rates through the filter control device in actual cubic feet
per minute (ACFM). Check literature or call the sales agent.
3. The water/moisture content of the gas stream going through the filter.
4.The amount of particulate in the gas stream going into the filter and the amount coming out if available.
Outlet default value = 0.016 grains PM10/dscf.
5.The pressure drop range across the system. Usually given in the literature in inches of water.
6. The temperature of the gas stream entering the filter system in degrees Fahrenheit.
7.The horse power of the fan used to move the gas stream and/or the flow rate of the fan in ft3/min.
8. Name of the manufacturer of the filter equipment and the model number if available.
9.Check the type of filter bag material or fill in the blank. Check literature or call the sales agent.
10. The diameter of the bags in the system. Check literature or call the sales agent.
11. The length of the bags in the system. Check literature or call the sales agent.
12. The number of bags. Check literature or call the sales agent.
13. The height to the top of the stack from ground level and the stack inside diameter.
14. The filtering efficiency rating that the manufacturer quotes. Check literature or call the sales agent.
15. The ratio of the flow rate of air to the cloth area (A/C).
16. The number of hours that the process equipment is in operation, maximum per day and per year.
17. The way in which the filters bags are cleaned. Check the appropriate box.
18.Supply calculations for all criteria pollutants and HAPs. Use AP42 or Manufacturers data to complete
your calculations.
U:\aq\ENGINEER\GENERIC\Forms 2010\Form10 Baghouses.doc
Revised 12/20/10
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Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data - For Modification/Amendment ONLY
1.Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2.Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3.Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4.Does new emission unit affect existing
permitted process limits?
Yes No
5.Condition(s) Changing:
6.Description of Permit/Process Change**
7.New or modified materials and quantities used in process. **
Material Quantity Annually
8.New or modified process emitting units **
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
Modification of two existing dust collectors in the Grinding Building to vent outside.
The Dust collectors are currently not used because the exhausts create air currents
that entrain process clay within the building into the air.
Doc.uim:i'ii D^lc: 02/28/2018
DAQ 2018-002274
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Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
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Interstate Brick #10423 Dust Collector NOI – Additional Information. Introduction. A review of the 2018 Title V permit and the Full Compliance Evaluation (FCE) dated 2022-03-10 shows that the Secondary Crusher/Grinding and Screens (SCG&S) are
referenced but not included in the Emission Inventory. To modify the existing dust collectors to vent outside the building the Potential To Emit (PTE) for the process needs to be calculated and added to the Facility’s PTE for PM¹º of 61.29 Tons and PM²·⁵ of 61.29 tons. The description of the Emission Unit is below.
Current Emissions. The current emissions from the Secondary Crusher/Grinding and Screens are fugitive PM emissions controlled by the enclosed building envelope. AP-42 Table 11.3-1 allots
an Uncontrolled PM¹º EF of 0.53 lbs per ton of Clay processed. The notes say that
grinding operations are typically conducted in an enclosed building but the EF does not take into account the effect of the building enclosure. Based on 2 tons of clay processed per minute and 6240 operational hours per year the additional Uncontrolled PTE is 0.53 x 2 x 60 x 6240 / 2000 = 198.43 tons each of PM¹º and PM²·⁵. This would
make the facility Title V for PM.
Building Attenuation Factor. Interstate Brick conducts regular Respirable Silica testing. As part of this, respirable Particulates (PM¹º) are measured. The results of three recent quarters of sampling from
within the SCG&S building averaged 69 mg/m³. Results from Line 2 which adjoins and
is directly beside the SCG&S building were an average of 1.6 mg/m³. 1.6 / 69 *100 = 2.32%. This is an attenuation factor of 97%. SCG&S Building – Current Emissions.
The uncontrolled emissions of 198.43 tons each of PM¹º and PM²·⁵, when controlled by
the building are 198.43 x .97 = 2.05 tons each. This will increase the PTE for PM¹º and PM²·⁵ from 61.29 tons each to 61.29 + 2.05 = 63.34 tons of PM¹º and PM²·⁵. This is well below the Title V limit of 100 tons each of PM¹º and PM²·⁵.

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Venting of the SCG&S Dust Collectors. From the Form 10 Emissions Calculations sheet and AP-42 Table 11.3-1, Controlled
PM¹º emissions from each Dust Collector are 0.0032 lbs per ton of clay processed. As
two tons of clay is processed each minute the annual PTE from both dust collectors will be 0.0032 x 2 x 60 x 6240 / 2000 = 1.20 tons each of PM¹º and PM²·⁵. Assuming that the emissions from the SCG&S building are now fully controlled this will
increase the PTE for PM¹º and PM²·⁵ from 61.29 to 62.49 tons each of PM¹º and PM²·⁵.
Summary. 1. By including the SCG&S emissions in the Facility PTE a long-standing anomaly is corrected.
2. By allowing the dust collectors to be properly vented, the working environment inside the SCG&S building will be dramatically improved. 3. If required, I can adjust other PM PTEs to keep the Facility PTE for PM at 61.29 tons.
Please let me know your questions and comments. Regards Greg Stevenson 2023-02-15
Form 10 (Baghouses) Emissions Calculations Assumptions.
1. The Title V limit is 2880 tons of Clay consumed per rolling 24 hour period
(Section II.B.1.a.(1). Of the TITLE V Permit #3500200001). 2. Both Baghouses are in use when the grinding room is operational. 3. 2880 TPD / (24 x 60) = 2 tons per minute of raw clay. 4. Each Dust Collector operates at 26,557 CFM.
5. EFs used are from AP-42 Table 11.3-2 SCC 3-05-003-02
6. Lbs / ft³ to gr / ft³ multiply by 7000. 7. 6240 operational hours per year. Sections II.B.2.e & II.B.3.e. PM¹º (Uncontrolled) for each Dust Collector. Processing of Dry Material.
EF = 0.53 lbs / ton of raw material processed. 0.53 / 26,557 = 0.0000197 lbs / ft³.
0.0000197 x 7000 = 0.14 gr /ft³ into each dust collector. PM¹º (Controlled) for each Dust Collector. Processing of Dry Material. EF = 0.0032 lbs / ton of raw material processed.
0.0032 / 26,557 = 0.00000012 lbs / ft³. 0.00000012 x 7000 = 0.00084 gr / ft³ exhausted from each dust collector.
Total PM (Uncontrolled) for each Dust Collector. Processing of Dry Material. EF = 8.5 lbs / ton of raw material processed. 0.19 8.5 / 26,557 = 0.00032 lbs / ft³.

0.00032 x 7000 = 2.24 gr /ft³ into each dust collector. Total PM (Controlled) for each Dust Collector. Processing of Dry Material.
EF = 0.0062 lbs / ton of raw material processed.
0.0062 / 26,557 = 0.00000023 lbs / ft³. 0.00000023 x 7000 = 0.00161 gr / ft³ exhausted from each dust collector.
Greg Stevenson 2023-02-09
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Interstate Brick – Permit Modification Additional Information.
The Facility is located in the Salt Lake County PM 2.5 2006 and Ozone 2015 Non-
attainment areas. The facility is a major source for Carbon Monoxide and has a Title V permit #3500200001. Facility ID is 10423.

The Technical contact for this application is Greg Stevenson (916 343 2108) [e-mail] Description of the Project
The project is a relatively straightforward modification of two existing Mikro Pul 80F4
pulse jet dust collectors. These units currently vent within the Grinding building. As a result , the two exhausts blowing inside the building create a swirl that entrains clay material into the air, creating a dust laden environment. As a result of this design flaw, the dust collectors have not been operated for many years.
As part of Interstate’s goal to improve facility air quality and lower emissions, the North Monsen Company has been engaged to design and install the exhausts and recommission the dust collectors.
Emissions Impact. Unfortunately the DEQs EDOCs site has been down and so I’m not yet able to review any emissions information, PTEs or fill out the Form 5. The qualitative impact of this change is that the fugitve PM emission sources in the Grinding Building will now be controlled. Other than installing ductwork, there will be no changes to any process or
throughput. BACT Analysis. The dust collectors are fitted with HCE treated polyester filters. HCE is a silicone spray that helps the bags pre-coat. This action can lower outlet emissions by up to three
orders of magnitude, though the manufacturer (Menardi Filter Systems) does not put a
fixed number on this because of equipment and material variabilities. Two other benefits of HCE treatment is stopping bag bleed through and helping to shed filter cake on pulsing. The HCE treated polyester bags provide the lowest achievable emission rate when fitted to the existing dust collectors.
Summary The exhaust modifications to the existing dust collectors will lower fugitive PM emissions at the facility. There will be a net effective reduction in PM emissions.
Pictures on the following page show one of the dust collector inlets on the top and the
outlet on the bottom.
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Greg Stevenson 2023-02-10
Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number 
2. Company contact (Name, mailing address, and telephone number)
3.Name and contact of person submitting NOI application (if different than 2) 4.Source Universal Transverse Mercator (UTM) coordinates 
5. Source Standard Industrial Classification (SIC) code 
6.Area designation (attainment, maintenance, or nonattainment)
7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8.Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers 
NOI Application Information: [R307-401]










N/A 
N/A 
A.Air quality analysis (air model, met data, background data, source impact analysis) N/A 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
N/A 
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
iJoc.i-iirKji'il Dale:' (X!/AS,‘2C U
DAQ 2018-002271
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Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
Facility: 10423
Title V: 3500200001
DAO 2018 002272